Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Assessing Officer initiated proceedings under section 147 solely on the basis of incriminating material seized during a search of a third party, but where information pertains to a person other than the searched party the proper statutory route is assessment under section 153C; therefore the AO lacked jurisdiction to proceed under section 147 and the appellate authority correctly quashed the 147 proceedings. Separately, additions for alleged 'on money' receipts were deleted because the AO extrapolated figures from seized documents without any corroborative evidence or independent inquiry, rendering the additions speculative and unsupported.
Assessing Officer initiated proceedings under section 147 solely on the basis of incriminating material seized during a search of a third party, but where information pertains to a person other than the searched party the proper statutory route is assessment under section 153C; therefore the AO lacked jurisdiction to proceed under section 147 and the appellate authority correctly quashed the 147 proceedings. Separately, additions for alleged 'on money' receipts were deleted because the AO extrapolated figures from seized documents without any corroborative evidence or independent inquiry, rendering the additions speculative and unsupported.
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TaxTMI 
TaxTMI 
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